’
Oi@NAL
.
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D. C. 20268-0001
POSTAL RATE AND FEE CHANGES, 2000
:
Docket No. R2000-1
FOLLOW-UP INTERROGATORIES OF ADVO, INC.
TO UNITED STATES POSTAL SERVICE WITNESS
LLOYD RAYMOND (ADVOIUSPS-T13-11 I-136)
Pursuant to sections 25 and 26 of the Rules of Practice, Advo, Inc. (Advo)
directs the following
Raymond.
interrogatories
These follow-up
to United States Postal Service witness
on his responses to MPA Interrogatories
57-109, received on March 23, 2000.
interrogatory,
witness
MPAIUSPS-T13-
If the witness is unable to respond to any
we request that a response be provided by an appropriate
capable
of providing
Lloyd
USPS
an answer.
Respectfully
submitted,
John M. Burzio
Thomas W. McLaughlin
Burzio & McLaughlin
1054 31st Street, N.W.
Washington, D. C. 20007
Counsel for ADVO, INC.
CERTIFICATE
OF SERVICE
I herebv certifv that I have on this date served the foreaoina
participants oi record in this proceeding in
Practice.
March 30, 2000
document
upon all
ADVO, INC. FOLLOW-UP
INTERROGATORIES
TO USPS WITNESS RAYMOND
ADVOIUSPS-T13-111.
In response to MPAIUSPS-T13-57,
you state that, when the
6-minute beep occurred, the observer took an instant snapshot of the carrier’s activity
and scanned in the observation as soon as possible. On page 6 of your testimony,
you state that your Stage 1 process design included a task inventory which included:
“1)
Followed carriers from time of arrival at the station (clock-in) to end of the
day (clock-out). Teams also traced routes from start to finish.
“2)
Compiled a list of activities performed/route
the list into a hierarchy.
“3)
Returned to the stations to follow carriers to insure the hierarchy
reflected activities performed/route
characteristics.
“4)
Adjusted hierarchy and finalized flow-process charts with a data
collection structure. Refer to Appendix A.” (Italics in original)
information
and arranged
“The work sampling data identified the frequency of occurrence
activity, which translated into the percent of time a carrier spent
performing certain activities.”
of an
With respect to these “instants,” activities, and hierarchy, please confirm the following
or explain fully why you cannot and provide all corrections. If none of the following are
correct, please explain fully how Appendix A of your testimony relates to your activity
sampling data collection and your testimony.
(a)
The list of activities and hierarchy to which you refer on page 6 are
represented in Appendix A on page 17 of your testimony (and similarly in
the flowcharts presented in LR I-220).
(b)
For purposes of the original activity sampling data collection, the intent of
collecting data was to categorize time proportions (i.e., instants of time)
into the general sets of activities described by the rectangles and circles
in Appendix A.
(4
Numerous specific carrier activities can be encompassed within each of
the general sets of activities described by the rectangles and circles in
Appendix A (for example, according to your response to MPA/USPS-T13109, the Appendix A term, “Load Vehicle,” includes moving full
hampers/containers
from unit across dock to vehicle, physically moving
mail from hampers/containers
into vehicle, rearranging mail/containers
within vehicle, moving empty hampers/containers
from vehicle, across
dock, and back to unit; the Appendix A term, “Drive to Park Point,”
-2includes any driving
deliveries).
(d)
for any delivery type except driving among curbline
Although the data collectors took “snapshots” of carrier activity being
observed, the codes used to describe those “snapshots” were designed
to categorize each snapshot into one of the general sets of activities
(represented by either one of the rectangles or one of the circles in
Appendix A).
ADVOIUSPS-T13-112.
In response to MPAAJSPS-T13-57, you state that, when the 6minute beep occurred, the observer took an instant snapshot of the carrier’s activity
and scanned in the observation as soon as possible. Please confirm the following or
provide a correction.
(4
With the exception of L18 (In Unit Walking), none of the Level 10 Location
codes indicate specific physical actions on the part of the carrier -- only
that carrier actions occurred at these locations at the instants of time
being observed.
(b)
None of the Level 11 .I (Personal or Administrative), Level 11.2 (Delivery
Type), or Level 11.3 (Delivery Type Status) codes, provided in LR l-163,
indicate specific physical actions on the part of the carrier at the instants
of time being observed.
w
The DO1 (No Access to Box), DO2 (Vehicle Breakdown), DO4 (Weather),
DO5 (Traffic/Detour), DO6 (No Work), DO8 (Delay Specify) activity codes
do not indicate specific physical actions on the part of the carrier -- only
that these conditions were somehow associated with a carrier activity at
the instants of time being observed.
Cd)
The F03 (Hardship), F04 (Delay-Specify) activity codes do not indicate
specific physical actions on the part of the carrier - only that a hardship
service or delay was somehow associated with a carrier activity at the
instants of time being observed.
(4
The FOI (Accountable), F02 (Parcel), JO4 (Parcels), and JO6 (Mix) activity
codes do not indicate specific physical actions on the part of the carrier only that accountable, parcel, parcels, or mix of mail was somehow
associated with a carrier activity at the instants of time being observed.
(9
The TOO-TO4 Travel activity codes do not indicate, by themselves, how
the carrier was physically moving or, even, whether the carrier was
actually moving.
-3.
ADVOIUSPS-T13-113.
T13-58:
With respect to the 933 video tapes mentioned
in MPANSPS-
(a)
Were tapes made of the entire route day for some or all routes?
explain how much time was taped per day on average.
@I
Please confirm that one of the observers
always took the videotape.
(c)
The number of videotapes
explain.
Please
on the team of two observers
exceeds the number of route-days.
Please
ADVOIUSPS-T13-114.
MPANSPS-T13-60
requested, for each route day, the
observer codes for all data collectors that collected data on that specific route day.
Your response indicates that you have provided that information in response to
MPANSPS-T13-16.
(a)
Please confirm that your response to MPANSPS-T13-16
provides no CY
codes or dates and does not provide sufficient data points to reflect all
route days in your LR l-163 data base.
(b)
Please provide, in spreadsheet format, the observer codes for each data
collector for each route day in LR l-163.
ADVOIUSPS-T13-115.
MPANSPS-T13-60
requests identification of data collectors
which had previous experience (in projects other than the one in which the activity
sampling data were collected) in observing postal delivery carriers for purposes of
identifying specific activities. Your response states that OBS12 and OBS13 had
collected data with the scanner on other non-postal clients.
(a)
Were OBS12 and OBS13 the only data collectors that had scanner
experience on other than this project?
(b)
Did any of the other data collectors have experience in observing postal
delivery carriers for purposes of identifying or measuring specific carrier
activities? If so, please identify each individual by observer code and
provide a brief description of his experience.
ADVOAJSPS-T13-116.
l
Your responses
to:
MPAAJSPS-T13-61
and 62 suggest that USPS LR l-220 (Engineered
Standards Book of Forms/Pictures) explains how to identify and
distinguish among each of the Level 10 Locations in Appendix D.
-A.
l
l
MPAAJSPS-T13-64
suggest that USPS LR l-220 explains how to identify
and distinguish among specific Level 11.2 Delivery Types.
MPANSPS-T13-78
suggest that USPS LR l-220 explains how Level
11.3.1 Activity Detail codes should be associated with Level 11.4 Activity
codes.
Please confirm that LR l-220 contains only the following.
why not and make all necessary corrections.
If you cannot, please explain
(4
Fourteen pages of sample USPS forms, none of which demonstrate
how to identify Locations, Delivery Types, Activity, or Activity Detail codes.
(b)
Eight pages of diagrams
w
A “Delivery-Basic” diagram that covers only three route types (park &
loop, walking, curbside) but does not explain how to identify them (as
either Level 11.2 or Level 11.3 codes), provides no explanation of when
one location or delivery type begins and the other ends, provides no
explanation of when one activity begins and the other ends, and provides
no explanation of how to apply the various (Level 11.4.1) activity detail
codes.
(d)
A “Delivery -Accountable”
diagram that does not use any terms which
are identical with the codes in your Appendix D, other than the Level 11.4
code for “Parcel” (FO2), provides no explanation of when one location or
activity begins and the other ends, and provides no explanation of how to
apply the various (Level 11.4.1) activity detail codes.
(6
A “Collection” diagram that does not use any terms which are identical
with the codes in your Appendix D, other than the Level Location code for
“Collection Box,” and the Level 11.4.1 code for “Collection Box,” provides
no explanation of when one location or activity begins and the other
ends, and provides no explanation of how to apply the various (Level
11.4.1) activity detail codes.
(9
Four pages of sample maps.
(9)
Thirteen pages of in-unit photographs, none of which show the dock or
demonstrate when the dock (Level 10) location begins or ends.
(h)
Seven pages of vehicle photographs, none of which explain how to
determine when vehicle location (Level 10) codes should be used.
of which five are diagrams
of in-office activities.
-5-
0)
Four pages of photographs of collection and relay boxes, none of which
explain how to determine when collection/relay box (Level 10) location
codes should be used.
Fifteen pages of photographs of mail receptacles, none of which explain
how to determine when various location codes (e.g., vehicle, point of
delivery, on route, in vehicle at stop, other route) should be used, how to
determine when various activity codes should be used, and none of
which (with the exception of gang box) show how to identify specific
receptacle codes.
Fifteen pages of photographs of mail in containers and various mail
receptacles, none of which can be related to any of the Location, Delivery
Type, Activity, or Activity Detail codes.
(4
ADVOIUSPS-T13-117.
l
l
Your responses
to:
MPANSPS-T13-61
and 62 suggest that USPS LR l-220 (Engineered
Standards Book of Forms/Pictures) explains how to identify and
distinguish among each of the Level 10 Locations in Appendix D.
MPNUSPS-T13-78
suggest that USPS LR l-220 explains how Level
11.3.1 Activity Detail codes should be associated with Level 11.4 Activity
codes.
Please confirm that LR l-220 contains no photographs of any carriers at any locations
and no photographs of any carrier activities. If you cannot, please explain why not and
provide all necessary corrections.
ADVOIUSPS-T13-118.
In response to MPNUSPS-T13-61
and 52, you state that
“the oral instructions provided to the observers” on how to identify and distinguish
among the Level 10 Location codes “are as shown in Appendix D to my testimony.”
On page 26, Appendix D, you state that Location Code LO9, Park Point, is “the point
where the vehicle is parked on Park and Loop routes.” However, on page 17,
Appendix A, you show “Park Points” for Central Inside, Central Outside, Dismount, and
Park and Loop routes. There also appear to be Park Point locations for non-Park and
Loop routes in the LR l-163 database. Despite the Appendix D definition, please
confirm that your data collectors scanned the Park Point LO9 code when the carrier
parked at many different locations and not just on loops. If you cannot, please explain
why not.
ADVOAJSPS-T13-119.
data collectors assigned
MPANSPS-T13-69(e)
asked for an explanation of why the
delivery type and delivery type status codes to locations that
-6were not at the point of delivery. Based on your best belief and understanding
the data collectors were instructed to do:
of what
(a)
Please explain the distinction between the tallies with delivery type and
delivery type status codes and those that do not have such codes.
(b)
Please provide all reasons for collecting that delivery type and delivery
type status codes for non-Point of Delivery locations.
ADVOIUSPS-T13-120.
Your response to MPANSPS-T13-65
indicates that, based
on USPS 3999X delivery types, when moving from one kind of delivery type/status to
another kind of delivery type/status, the observer would change the delivery type when
traveling to the next (new) delivery type/status.
MPANSPS-T13-69(c)
and (d)
requested all systematic guidance given to the data collectors on how to identify
delivery type and delivery type status when the carrier was not at the point of delivery.
For the following, please provide your best belief and understanding.
If you do not
know the answer, please so state. If no instructions were given, please so state.
(a)
For all carrier activities prior to the first delivery of the day, did the
observers scan the delivery type/status for the first possible (as opposed
to actual) delivery of the day? Please explain,
(b)
For all carrier activities after the last delivery of the day, did the observers
scan the delivery type/status for the last possible (as opposed to actual)
delivery of the day? Please explain.
(4
If a delivery was typically curbline but, on the observed route-day, a parcel
or accountable had to be dropped to the address, were the data
collectors instructed to scan curbline type (with either outside residential
or business status) or to scan dismount (with inside residential or
business status)? Please explain.
(4
If a delivery was typically central, park & loop, or foot, and the delivery
status was typically outside residential or business, but on the observed
route-day, a parcel or accountable had to be dropped to the address,
were the data collectors instructed to scan outside residential or
business or inside residential or business?
Please explain.
63
In response to MPANSPS-T13-91,
you confirm that there are no tallies
allocating Curbline Delivery type to Drive Time. In response to
MPAAJSPS-T13-92
you confirm that the observers could tell when a
curbline set of deliveries was coming up. Do these facts mean that, on
the observed routes, curbline deliveries always preceded other
motorized delivery types and the observed carriers never drove from
another delivery type to a curbline set of deliveries? Please explain.
-7-
ADVOIUSPS-T13-121.
In response to MPANSPS-T13-74(c),
you state that Level
11.4 Activity code FOI (Accountable) means that the carrier is handling, delivering, or
processing an accountable type of mail.
(4
Please confirm that FOI does not necessarily mean that the carrier was
preparing mail to place into a mail receptacle, inserting mail into a
receptacle or handing mail to an addressee at the observed instant of
time. If you cannot, please explain why not.
(b)
Please confirm that “delivering” as used in your statement is used
broadly in the sense that the carrier intends to get the accountable to the
addressee and does not mean physically placing the accountable in the
addresee’s hands or mail receptacle. If you cannot, please explain why
not.
ADVOIUSPS-T13-122.
In response to MPANSPS-T13-75(c),
you state that Level
11.4 Activity Code F02 (Parcel) means that the carrier is handling, delivering, or
processing a parcel type of mail.
(a)
Please confirm that F02 does not necessarily mean that the carrier was
preparing mail to place into a mail receptacle, inserting mail into a
receptacle, or handing mail to an addressee at the observed instant of
time. If you cannot, please explain why not.
(b)
Please confirm that “delivering” as used in your statement is used
broadly in the sense that the carrier intends to get the accountable to the
addressee and does not mean physically placing the parcel in the
addresee’s hands or mail receptacle. If you cannot, please explain why
not.
ADVOIUSPS-T13-123.
In response to MPNUSPS-T13-76(c),
you state that Level
11.4 Activity Code JO4 (Parcels) means that the carrier is handling, delivering, or
processing a parcel type of mail.
(4
Please confirm that JO4 does not necessarily mean that the carrier was
preparing mail to place into a mail receptacle, inserting mail into a
receptacle, or handing mail to an addressee at the observed instant of
time. If you cannot, please explain why not.
lb)
Please confirm that “delivering” as used in your statement is used
broadly in the sense that the carrier intends to get the parcels to the
addressee and is not intended to mean physically placing the parcels in
-6the addresee’s
why not.
hands or mail receptacle.
If you cannot, please explain
ADVOIUSPS-T13-124.
In response to MPA/USPS-T13-57,
you state that, when the
6-minute beep occurred, the observer took an instant snapshot of the carrier’s activity
and scanned in the ObseNation as soon as possible.
Please refer to your response
to MPAAJSPS-T13-36
where you state that the Level 11.4 Activity Code of “Finger @
Delivery” (J12) includes “.
the actions of the carrier obtaining the mail while at the
delivery point from the hand, and/or arm, and/or satchel, verifying the mail, and
depositing the mail.” For purposes of your activity sampling data collection:
(a)
Please confirm that your MPA/USPS-Tl-36
definition differs from the one
previously provided in Appendix D. The response includes obtaining
mail, verifying the mail, and depositing the mail while the Appendix D
definition indicates that only “fingering through the mail to verify the
address is correct and collecting the mail to deposit” is observed.
(b)
Please confirm that only one of the actions described in (a) above may
have been observed at a specific instant of time, when the “Finger @
Delivery” code was scanned. If you cannot, please explain why not.
(c)
To your best belief and understanding, were there any other actions that
may have also been observed when the “Finger @ Delivery” barcode
was scanned?
Please explain.
(d)
If the code for “Finger @ Delivery” includes the action of depositing the
mail, then, to the best of your belief and understanding, please identify
every routine physical carrier action that you believe your data collectors
may have been observing when they scanned the “Delivery/Collection”
(J08) code. If this may vary by delivery type (e.g., curbline vs. park &
loop), please explain fully.
ADVOAJSPS-T13-125.
In Appendix D, you describe Code JO9, Loading, as putting
mail into a vehicle. In response to MPAIUSPS-T13-105,
you state that “Loading is
moving trays from a hamper or nutting truck to the rear of the vehicle.”
(4
In response to MPAAJSPS-T13-109,
you state that there were JO9
(Loading) tallies where the “data collectors were probably observing a
carrier inside the unit either on his way out to load a vehicle, or on his
way back in to get more mail to load the vehicle.” Please confirm that,
according to your definition, such tallies do not accurately record the
observed instant of time as a Loading activity.
-9-
(b)
Please confirm that there are code JO9 Loading tallies at Level 10 Relay
Box (Lll) locations. If you cannot, please explain why not.
Cc)
Please confirm that there are code JO9 Loading tallies at Level 10 Park
Point (LO9) locations. If you cannot, please explain why not.
(4
Please confirm that there are code JO9 Loading tallies at Level 10
Miscellaneous (L15) locations, where (per your response MPANSPST13-63) Miscellaneous locations are such areas as elevators, phone
booths, supervisor’s desks, customer’s lawn, locked keys in vehicle, in
vehicle parking lot due to no work. If you cannot, please explain why not.
(4
Please identify every routine physical carrier action that you believe your
data collectors may have been observing when they scanned the
“Loading” (JO9) code. If you cannot, please so state.
ADVOIUSPS-T13-126.
In response to MPANSPS-T13-105,
you state that “Setup”
(Activity Code Jll) is “loading the satchel or moving trays to the front of the vehicle.”
Please identify every routine physical carrier action that you believe your data
collectors may have been observing when they scanned the “Setup” (Jll) code.
ADVOIUSPS-T13-127.
In Appendix D, you describe Activity Code JIO, Unloading,
as “Taking empty trays, tubs, collected mail etc. out of vehicle typically at the end of
day.”
(4
Please confirm that there are Code JIO Unloading tallies at both Level
10 Collection Box (LIO) and Relay Box (Lll) locations. If you cannot,
please explain why not.
(b)
Please confirm that there are code JIO Unloading tallies at Level 10
Miscellaneous (L15) locations, where (per your response MPANSPST13-63) Miscellaneous locations are such areas as elevators, phone
booths, supervisor’s desks, customer’s lawn, locked keys in vehicle, in
vehicle parking lot due to no work. If you cannot, please explain why not.
(4
Please confirm that there are code JIO Unloading tallies at Level 10
Park Point (LO9) locations. If you cannot, please explain why not.
(d)
Please identify every routine physical carrier action that you believe your
data collectors may have been observing when they scanned the
Unloading” (JIO) code. If you cannot, please so state.
-lOADVOIUSPS-T13-128.
In response to MPNUSPS-T13-67(c),
you state that “The
TO5 code [walking] was used when the carrier was walking other than the other
defined codes.” The other Activity codes were TO1 Travel to First Delivery Point, TO2
Travel b/t Delivery, and TO3 Travel b/t w/Sort.
(4
Please confirm that there are walking code (T05) tallies at both On Route
(L13) and Point of Delivery (L12) locations, If you cannot, please explain
why not.
0))
Among a set of park & loop deliveries within one loop, under what typical
circumstances do you believe your data collectors may have scanned
the TO5 code? If you cannot identify the typical circumstances, please
explain fully why not.
Cc)
On a dismount delivery, under what typical circumstances do you believe
your data collectors may have scanned the TO5 code? If you cannot
identify the typical circumstances, please explain fully why not.
(d)
On a set of foot deliveries within one relay, under what typical
circumstances do you believe your data collectors may have scanned
the T05? If you cannot identify the typical circumstances, please explain
fully why not.
(4
On a central delivery, under what typical circumstances do you believe
your data collectors may have scanned the TO5 code? If you cannot
identify the typical circumstances, please explain fully why not.
ADVOIUSPS-T13-129.
In response to MPANSPS-T13-80,
you state that the Code
H activity details (i.e., mail receptacles) describe the receptacle or collection box ,(X%X
the carrier. Please confirm that these codes do not necessarily mean the carrier was
physically handling a receptacle at the instant of time observed. If you cannot, please
explain why not.
ADVOIUSPS-T13-130.
For the Code K activity details (i.e., Jeep, LLV, Walking,
Walk Flat, etc.), please provide your belief as to the observers’ interpretation of the
following:
(4
Did any of the vehicle codes (i.e., Jeep, LLV, 1 or 2 ton truck, pickup/van,
bus, automobile, elevator) mean the carrier is physically inside or
moving the vehicle, doing something with the vehicle (i.e., locking it or
pulling mail out of the back), or simply near the vehicle? Please explain.
(b)
What were the differences among the “Walking” (K09), “Walk Flat” (KIO),
and “Walk Obstructed” (Kll) codes?
‘.
-ll-
ADVOIUSPS-T13-131.
you state that you cannot,
activity detail (e.g., public
allocated to the STS Load
Please refer to your response to MPANSPS-T13-94
where
without specific records, explain why virtually all the Code G
relations, service rates, directions, excess words) were
category.
(a)
Please confirm that when a Code G Activity Detail was scanned, that
does not necessarily mean that the carrier, at that instant, was physically
handling mail, a mail satchel/container
(other than physically carrying it),
or a mail form.
(b)
Please confirm that the Activity code associated with a Code G Activity
Detail (such as Activity Code F04 “Delay Specify”), does not provide any
additional information to determine whether the carrier was physically
handling mail, a mail satchel/container
(other than physically carrying it),
or a mail form.
Cc)
Please confirm that a Code G Activity Detail can occur at many different
Locations, and not just at Point of Delivery.
ADVOIUSPS-T13-132.
In response to MPAAJSPS-T13-57
(b), 61(b), 64(b), and
67(f), questions regarding the systematic efforts made to ensure that the codes were
consistently and correctly applied by all data collectors, you state that “USPS Subject
Matter Experts and the roving quality assurance personnel would spot check the
observations.
The work sampling scans were cross-checked with the time study
records, observer comments and video tapes.”
(4
Please describe the qualifications of a roving quality assurance person
and state whether such a person was a Resource & Process metrics,
Inc. employee, an employee of another consulting firm, or a USPS
employee.
(b)
Were USPS Subject Matter Experts and roving quality assurance
personnel used in both Phases 1 and 2? Please explain and provide
the number of such experts and number of quality assurance personnel
in Phases 1 and 2, separately.
(c)
Was some portion of each route-day observed by a USPS Subject Matter
Expert and a roving quality assurance person? If not, please identify the
route-days for which a portion of time was observed by either a USPS
Subject Matter Expert or roving quality assurance person.
Cd)
Typically, when observed, how much of a route-day was observed
USPS Subject Matter Expert or roving quality assurance person?
by a
-12-
(e)
Was some portion of each route-day cross-checked with the time study
records, observer comments and video tapes? If not, please identify the
route-days that were cross-checked by each method.
(9
Were the cross-checks performed by both the USPS Subject Matter
Experts and roving quality assurance personnel?
If not, who performed
the cross-checks?
(9)
Typically, how much of a route-day was cross-checked by a USPS
Subject Matter Expert, roving quality assurance person, or some other
person?
(h)
Were you a roving quality assurance person and did you personally
cross-check any of the time study records, observer comments and
video tapes?
ADVOIUSPS-T13-133.
Interrogatories MPANSPS-T13-86
and 99 provided lists of
types of tallies grouped by the STS categories to which they had been assigned, and
asked you to explain why you assigned them to the particular STS category. You
declined to respond on the ground that “I cannot respond without references to the
specific records in question, including CY code, route ID, date, etc.” As an alternate
approach to help understand in general terms your assignments of various types of
tallies to STS categories (including the tally types listed in MPA-86 and MPA-99)
please refer to your testimony at page 14 where you discuss your initial manual
assignment of STS categories to the tallies, followed by your creation of a “master list”
of scan sequences grouped by STS category, which you state was used “to
crosscheck the manual review process.” In response to ADVOIUSPS-T13-22(c)
which asked you to provide the master list of scan sequences, you responded
“Please refer to Appendix D and Appendix F of my testimony.”
(a)
Please confirm that Appendix D does not contain the “master list” of scan
sequences grouped by STS category, because it does not contain any
information about STS categories.
(b)
Please refer to Appendix F and the table below. This table lists, for each STS
category, the “Locations” shown in your Appendix F (in the second column)
compared to the “Locations” that are found in the LR l-163 database (in the
third column). Please confirm that this is an accurate list of the Locations by
STS category shown in Appendix F and appearing in LR l-163. If you cannot
confirm, please explain why not.
(4
Please confirm that some of the locations that appear in LR l-163 but not in
your Appendix F also appear on the MPA interrogatories (e.g., MPANSPS-T13ww)~
(wlh (WW).
Please explain why the location information by STS category in Appendix F
differs from the location information in the LR l-163 database.
(4
-13-
STS Categories
Load Time
Street Support Time
Locations Listed in
USPS-T-13 Appendix F
On Route
Point of Delivery
Vehicle
Dock
Gas Station
Vehicle
PSL
On Route
Relay Box
Park Point
Collection Box
Miscellaneous
Driving Time
Vehicle
In Vehicle at Stop
On Route
Park Point
Miscellaneous
SAT
Vehicle
In Vehicle at Stop
On Route
In Vehicle Traffic
Miscellaneous
=AT
On Route
Miscellaneous
’
Wait While Walking
Zollection
Collection Box
Locations Included in
LR l-163
On Route
Point of Delivery
Vehicle
Park Point
Other Route
Miscellaneous
In Vehicle at Stop
N/A
Dock
Gas Station
Vehicle
PBL
On Route
Relay Box
Park Point
Miscellaneous
In Unit Walking
In Vehicle at Stop
F,phicle Traffic
Point of Delivery
Wait When Walking
Vehicle
In Vehicle at Stop
On Route
Park Point
Miscellaneous
Wait When Walking
Vehicle
In Vehicle at Stop
On Route
In Vehicle Traffic
Miscellaneous
Other Route
Point of Delivery
On Route
Miscellaneous
Wait While Walking
Vehicle
Park Point
Collection Box
Miscellaneous
On Route
ADVOIUSPS-T13-134.
Please refer to the preceding interrogatory and Appendix F
to your testimony. The table below lists, for each STS category, the “Activities” shown
in your Appendix F (in the second column) compared to the “Activities” that are found
in the LR l-163 database (in the third column).
-14 -
Please confirm that this is an accurate list of the Activities by STS category
shown in Appendix F and appearing in LR l-163. If you cannot confirm, please
explain why not.
Please confirm that some of the Activities that appear in LR l-163 but not in your
Appendix F also appear on the MPA interrogatories (e.g., MPA/USPS-T1386(kk), (ww); MPAIUSPS-T13-99(n),
(aa), (bb), (cc), (gg), (kk), (tt)).
Please explain why the Activities information by STS category in Appendix
differs from the Activities information in the LR l-163 database.
STS
Categories
-oad Time
Activities Listed in
USPS-T-13 Appendix F
Delivery/Collection
Parcel
Finger @ Delivery
Setup
Accountable
Delay Specify
Street
Support
hrK?
Loading
Unloading
Setup
Travel to lSt Delivery
Return to Unit
Delay Specify
F
Activities Included in
LR I-l 63
Delivery/Collection
Parcel
Finger @ Delivery
Setup
Accountable
Delay Specify
NIA
Delay Specify Detail
Walking
Hardship
No Access to Box
Travel Between Deliveries
Travel Between Deliveries with
sort
Loading
Unloading
Setup
Travel to Ist Delivery
Return to Unit
Delay Specify
Delay Soecify Detail
DeliveylCollection
N/A
Walking
Mix
Travel Between Deliveries
No Work
Wait 4 Collection
Parcels
Mix
‘.
- 15-
ST6
Categories
Driving Time
Activities Listed in
USPS-T-13 Appendix F
Travel Between Deliveries
Traffic/Detour
Delay
Ve$le Breakdown
CAT
Travel Between Deliveries
Traffic/Detour
Delay Specify
FAT
Travel Between Deliveries
N/A
Accountable
Parcel
Collection
Delivery/Collection
Setup
Unloading
Wait for Collection
Activit;;
;n,cllded in
Travel Between Deliveries
Traffic/Detour
Delay - Specify
~-II:
Breakdown
Travel to First Delivery
N/A
Delay Specify Detail
Accountable
Delivery/Collection
No Access to Box
Weather
Travel Between Deliveries
Traffic/Detour
Delay Specify
Vehicle Breakdown
Delay Specify Detail
Parcel
Accountable
N/A
Weather
Travel Between Deliveries
N/A
Accountable
Parcel
Delay Specify
Walking
No Work
No Access to Box
Travel Between Deliveries with
sort
Travel to lSt Delivery
Delivery/Collection
Setup
Unloading
Wait for Collection
In view of the disparity in the Locations and Activities by STS
ADVOIUSPS-T13-135.
category between (i) your Appendix F, and (ii) both the LR l-163 database as shown in
Advo Interrogatories 133-134 and the tally types listed in MPA/USPS-T13-86
and 99
[which you say you cannot respond to without specific tally references], please
respond to the following:
(a)
At page 14 of your testimony, you discuss the process by which you assigned
STS categories to the observations in the database, beginning with a line-by-line
manual assignment.
At page 14 (lines 18-20) you then state:
-16“To crosscheck the manual review process, a master list was
created of scan sequences.
The sequences were grouped
according to STS activity. All scan sequence possibilities for an
STS activity were assigned a 1-6 code.”
Is your Appendix F, in fact, the “master list” of scan sequences,
in your response to ADVO/USPS-T13-22(d)?
as you claimed
(b)
We have not been able to replicate either a “master list” of scan sequences
your Appendix F. Explain precisely, in a step-by-step manner sufficiently
detailed to allow other parties to follow and replicate your results, how you
created this “master list” of scan sequences “grouped according to STS
activity.”
(c)
What was the source for creation of the “master list” of scan sequences?
If it
was something other than the database developed in the initial manual review
process, please provide the source materials in their entirety, and explain how
those source materials were used to create the “master list.”
03
Please provide a copy of the “master list” created by the process described in
subparts (b) and (c) above. If you claim that Appendix F is the “master list,”
please explain how Appendix F was created so that other parties might
replicate it.
(e)
With respect to your use of the “master file” to “crosscheck the manual review
process” (Testimony at page 14, line 18) Webster’s Third New International
Dictionary defines “cross-check” as “to check (as data, reports, statements)
from various angles or sources to determine accuracy or validity.” Is your use
of the term “crosscheck” consistent with this definition?
(9
(1)
If so, explain why.
(2)
If not, please explain more precisely what you meant by the term
“crosscheck.”
or
Please state whether or not the “crosscheck” procedure you describe checked
the database developed in the manual sequence review step “to determine
accuracy or validity” of the manual STS entries. If your answer is anything other
than “No,”
(1)
Please explain precisely how your crosscheck procedure checked the
accuracy or validity of either the observed database entries or the
manual STS entries.
(2)
Please identify each and every record or tally in LR l-163 where the
“crosscheck” procedure resulted in either (i) a change in the STS
.
.
-I?category assigned to the tally or (ii) a change in the other observerrecorded fields of the tally. For each such change, please provide the
original information before the change, and explain why the change was
made.
(9)
In your testimony, from page 14 line 20 through page 15 line 2, you state that
after creation of the “master list” of scan sequences:
“An update query was then used to assign the sequences a code
in the database. These codes appear in the Library Reference
USPS-LR-I-163 with the column header ‘STS Type.’ ”
(1)
Please confirm that this quoted statement is inconsistent with your
statement at page 14, lines 16-17, that “The column ‘STS Type’ contains
definitions entered by manual sequence review.”
(2)
Please confirm that the codes you refer to at page 15 are numeric codes,
not text fields.
(3)
Please confirm that these numeric codes appear in LR l-163 under the
column header “File,” not under the column header “STS Type.”
(4)
Please confirm that the information in the LR l-163 database under the
column header “STS Type” consists of the STS category entries “entered
by manual sequence review” described at page 14, lines 13-16. If you
do not confirm,
(0
Please identify each and every record or tally in LR l-163 where
the actual STS category shown in the “STS Type” field differs from
the STS category that was manually entered in the initial “manual
sequence review.”
(ii)
For each such record, please provide the STS type that was
initially entered manually, and the different STS type that appears
in LR l-163.
(iii)
For each such record, please explain at what point in the process
described at pages 14-15 the STS type was changed, the reason
for the change, and the methodology by which it was changed.
If you cannot confirm any of (l)-(4) above, please explain fully why not, including
an explanation of the correct meaning and content of the “File” and “STS Type”
column headers, and the source and derivation of the STS-related information
contained in those fields.
-18 (h)
At page 14 line 19 through page 15 line 2, you state that after the “master list” of
scan sequences was created,
“All scan sequence possibilities for an STS activity were assigned a l-6
code. An update query was then used to assign the sequences a code
in the database. These codes appear in the Library Reference USPSLR-I-163 with the column header ‘STS Type.’ ”
Please respond to the following with respect to this “update query.”
(i)
(1)
Provide and describe the full Microsoft Access@ query or queries that you
actually used.
(2)
What information does the “update query” actually update? Please be
specific, and provide examples of the results of the “update query”
process.
(3)
Explain precisely, in a step-by-step manner sufficiently detailed to allow
other parties to follow and replicate your results, how you created this
update query, what the update query does, and how it is executed.
(4)
Was the “update query” designed or intended to either flag for review,
check the accuracy, or change in any manner (i) any of the observerentered data in the database, or (ii) any of the manual STS assignments
made during the initial “manual sequence review?” If so,
(9
Please explain how the update query flags for review, checks for
accuracy, or changes the database information in any manner.
(ii)
Please identify each and every record in LR l-163 where, as a
result of the “update query” process, the actual STS category
shown in the “STS Type” field was changed from the STS category
that was manually entered in the initial “manual sequence
review,” and for each such record provide the original manuallyentered STS type.
(iii)
Please identify each and every record in LR l-163 where, as a
result of the “update query” process, changes were made to any
of the observer-entered
information, and for each such record
provide the original observer-entered
information.
Please explain, on a step-by-step basis, precisely how a party, working with the
collected tally information contained in all but the last two fields of the LR l-193
database (“File” and “STS Type”), can replicate your assignments of tallies to
the various STS categories. For each step,
- 19-
(1)
Please provide (and explain in plain language) all programs, formulas,
queries, algorithms, etc. that are used in that step of the replication,
(2)
Please explain the rationale or logic underlying
(3)
Please explain precisely how a party would apply and execute the
programs to reproduce your STS assignment results.
such programs,
etc.
Please refer to the following:
l
l
Subparts
(a)-(i) of this interrogatory
and your responses
thereto, and
Your “responses” to MPA Interrogatories MPANSPS-T13-83,
85-90,
93, 94, 96, 97, 99-101, 106 and 108, where you state that you cannot
respond to questions concerning the interpretation and STS
classification of types of tallies or even hypothetical questions
“without references to the specific records in question, including CY
code, route ID, date, etc.”
Is your inability to address questions about the STS classification of types of
tallies without references to the specific tallies related in any manner to the
possibility that the actual STS Type entries in LR l-163 are, in the case of each
of the 39,046 records, the result of the manual, line-by-line assignment
described in your testimony at page 14, lines 13-17? Please explain.
ADVOIUSPS-T13-136.
Please refer to MPANSPS-T13-104.
You state that lunch
break tallies were deleted from the databases provided to witness Baron. It appears
that tallies for other personal break observations were also deleted prior to the activity
sampling data being converted to the LR l-163 data set.
(a)
Please confirm that other personal
break tallies were also deleted.
(b)
Were any other types of out-of-office
explain fully.
(4
Please explain how one can determine from the LR l-163 data set the
extent to which carriers took lunch or other personal breaks.
(4
Please explain how one can determine from the LR l-163 data set the
number of workhours the carriers spent out-of-office.
tallies also deleted?
If so, please